This presentation will discuss the differing federal income tax treatment from granting compensatory capital and profits interests. This presentation will also discuss the differing treatment of compensatory profits interests under the existing authority – i.e., Revenue Procedures 93-27 and 2001-43 – as opposed to the 2005 Proposed Regulations. In addition, this presentation will address provisions that should be included in Partnership Agreements to ensure the tax-free grant of compensatory profits interests.
Compensatory Capital Interests
Compensatory Profits Interests
Partnership Agreement Provisions Relating to Compensatory Profits Interests
Course Level: Intermediate
Prerequisite: Federal Income Taxation of Partnerships
Course Number: 174219053
CPE Credit: 1.20 Hrs.
MCLE Credit: 1.00 Hr.
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Mr. Beck is a Board Certified tax attorney who provides Federal income tax and Texas franchise and sales tax advice to businesses of all types and sizes, including Subchapter C corporations, Subchapter S corporations, partnerships, limited liability companies, and entities disregarded for Federal income tax purposes. He advises on tax issues arising during all phases of business operations, including formation, restructuring of ownership interests, acquisitions, dispositions, mergers, consolidations, liquidations, international transactions, issuance of deferred and equity compensation, and business succession planning. He represents businesses and entrepreneurs in a broad range of industries, including professional services, manufacturing, technology, oil and gas, and real estate. He also advises tax-exempt organizations under Section 501 of the Internal Revenue Code.
Mr. Beck also represents individuals, businesses, and estates in tax related controversy matters, including Internal Revenue Service audits, appeals, and litigation in Federal courts, including the U.S. Tax Court and Fifth Circuit Court of Appeals. He also represents taxpayers in franchise and sales tax disputes with the Texas Comptroller of Public Accounts.
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